From Morse v. Frederick (emphasis added),
For example, Congress has declared that part of a school’s job is educating students about the dangers of drug abuse, see, e.g., the Safe and Drug-Free Schools and Communities Act of 1994, and petitioners and many other schools have adopted policies aimed at implementing this message.
Perhaps its my lack of formal legal training but I was not aware that Congress played the role of national school board. Congress can, of course, spin as many strings as it wants on the funding it gives states for education, but otherwise it has no power over the schools and certainly does not dictate their mission.
If “the petitioners and many other schools” have adopted policies aimed at implementing this message (is it a message, or a legal obligation?), what about the schools that have not? Are they remiss in their Congressionally mandated obligation to instruct children about the dangers of bong hits? (Bongs sent fewer teens to their deaths than expeditionary wars, but Congress still funds the latter).